SEC Comment Letter 0000000000-22-013100 to Freshworks Inc. (FRSH) (CIK 0001544522) (FRSH)
Freshworks Inc. (FRSH) (CIK 0001544522)
Date: Dec. 6, 2022 · CIK: 0001544522 · Accession: 0000000000-22-013100
AI Filing Summary & Sentiment
File numbers found in text: 001-40806
Letter
United States securities and exchange commission logo December 6, 2022 Rathna Girish Mathrubootham Chief Executive Officer Freshworks Inc. 2950 S. Delaware Street, Suite 201 San Mateo, CA 94403 Re:Freshworks Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed February 23, 2022 File No. 001-40806 Dear Rathna Girish Mathrubootham: We have reviewed your December 2, 2022 response to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our November 17, 2022 letter. Form 10-K for the Fiscal Year Ended December 31, 2021 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Key Business Metrics, page 50 1.We note from your response to prior comment 1 that you consider the number of customers contributing more than $5,000 in ARR and net dollar retention rate to be the best indicators of trends in your business. Therefore, tell us your consideration to disclose these metrics for each period in which financial statements are provided (e.g. fiscal 2019). Results of Operations, page 54 2.We note your response to prior comment 3 where you state that you will disclose the net dollar retention rate and number of paying customers in future filings to explain the increase in revenue from new versus existing customers. Please also disclose the
FirstName LastNameRathna Girish Mathrubootham Comapany NameFreshworks Inc. December 6, 2022 Page 2 FirstName LastName Rathna Girish Mathrubootham Freshworks Inc. December 6, 2022 Page 2 percentage or dollar amount of change in revenue attributable to both new and existing customers to add further context to the impact of such metrics on your revenue growth. You may contact Megan Akst, Senior Staff Accountant at 202-551-3407 or Kathleen Collins, Accounting Branch Chief at 202-551-3499 if you have questions. Sincerely, Division of Corporation Finance Office of Technology cc: Jon Avina
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United States securities and exchange commission logo
December 6, 2022
Rathna Girish Mathrubootham
Chief Executive Officer
Freshworks Inc.
2950 S. Delaware Street, Suite 201
San Mateo, CA 94403
Re:Freshworks Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed February 23, 2022
File No. 001-40806
Dear Rathna Girish Mathrubootham:
We have reviewed your December 2, 2022 response to our comment letter and have the
following comments. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
November 17, 2022 letter.
Form 10-K for the Fiscal Year Ended December 31, 2021
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Key Business Metrics, page 50
1.We note from your response to prior comment 1 that you consider the number of
customers contributing more than $5,000 in ARR and net dollar retention rate to be the
best indicators of trends in your business. Therefore, tell us your consideration to disclose
these metrics for each period in which financial statements are provided (e.g. fiscal 2019).
Results of Operations, page 54
2.We note your response to prior comment 3 where you state that you will disclose the net
dollar retention rate and number of paying customers in future filings to explain the
increase in revenue from new versus existing customers. Please also disclose the
FirstName LastNameRathna Girish Mathrubootham
Comapany NameFreshworks Inc.
December 6, 2022 Page 2
FirstName LastName
Rathna Girish Mathrubootham
Freshworks Inc.
December 6, 2022
Page 2
percentage or dollar amount of change in revenue attributable to both new and existing
customers to add further context to the impact of such metrics on your revenue growth.
You may contact Megan Akst, Senior Staff Accountant at 202-551-3407 or Kathleen
Collins, Accounting Branch Chief at 202-551-3499 if you have questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Jon Avina